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Filing # 129911438 E-Filed 07/01/2021 01:22:43 PM
Lisa DiSalle, Esq.
FL Bar No.: 186236
Joshua James Knurr
FLBar No..:1016695
American Express Legal
9550 Regency Square Blvd., Suite 501
Jacksonville, FL 32225
844-641-4041
Primary Email:
Secondary Service Email:
Staff Attorney for Plaintiff
AMERICAN EXPRESS NATIONAL BANK,
IN THE CIRCUIT COURT
17TH JUDICIAL CIRCUIT, IN AND FOR
Plaintiff, BROWARD COUNTY, FLORIDA
-against-
CASE NO. : CACE-21-007763
DANIEL SALGADO
Division :
a/k/a DANIEL J SALGADO
Defendant(s)
STIPULATIONOF
SETTLEMENT
AMERICAN EXPRESS NATIONAL BANK ("Plaintiff) a national bank
organized under the laws of the United States, ("American Express" hereinafter), with its
headquarterslocated at 115 W. Towne Ridge Parkway, Sandy UT 84070.
IT IS HEREBY STIPULATED AND and between the
AGREED, by Attorney(s) for
Plaintiff(s) and Defendant(s)and/or the
Attorney(s) for the Defendant(s) that this matter has
been discussed and a settlementhas been agreed to upon the following terms:
***
FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 07/01/2021 01:22:43 PM.****
1. Detendant(s) acknowledges service and receipt of the Summons and
Complaint. Defendant(s) hereby withdrawsany answer, counterclaim or third-partycomplaint
and waives any and all offsets,defenses, and claims
against Plaintiff(s) and its/their attorney(s).
2. Defendant(s) agrees to pay Plaintiffthe settlement sum of $97,316.30 on account
number REDACTED An initial
payment of $4,055.00 was made by June 7, 2021,
Thereafter, Defendant(s)agrees to pay Plaintiff(s)consecutive monthly
payments of $4,055.00
due on or before the 78 of each and everymonthcommencing
July, 2021 through and including
April, 2023. Then, one final payment of $4,051.30 is due on or before the
May 7,2023.
3. Upon full payment of all payments required under this agreement, Plaintiff(s)
shall send, appropriate,
as a
stipulation of dismissal with
prejudice or warrant to satisfy
judgment to the Defendant(s) and to the Court within 30 days. However, if Defendant(s) fails
to make any
payment required under this agreement, Plaintiff(s) also referred to as American
Express shall provide Daniel Salgado a/Ida Daniel J Salgado with written notice ofthe default
and an
opportunity to cure via regular mail and certifiedmail, return receiptrequested. If the
event of Default is not cured within ten
(10) days from the date ofmailing said notice certified
mail, return receipt requested, then upon certification of counsel and without notice to the
Defendant(s),Plaintiff(s)will be entitled to Judgment in the amount of $97,316.30 as
per the
Complaint, less any payments made or referenced hereunder, plus costs. Further, Daniel
Salgado a/Ida Daniel J Salgado will only be entitled to a maximum of one (1) notice of default
and opportunity to cure
during the lifetime of this Agreement.
4. AH payments are to be sent to American
Express P.O. Box 278, Ramsey, New
Jersey 07446, by check payable to American Express
referencing Account Number REDACTED
REDACTED (the "Accounf).
5. This agreement resolves all claims each
signatory party hereto may have against
the other with respect to the Account which is
the basis ofthis action.
6. Except for the terms and conditionscontained herein
Defendant(s)
acknowledgesand represents that he possesses no claims, demands, defenses,
counterclaims,
or causes of action whatsoever
against American Express, its officers, directors, employees,
agents, attorneys, heirs and assigns, pertaining to Account No.
REDACTED which
are not being resolved
pursuantto this Agreement. Defendant(s) forever waives and
relinquishes any and all such claims, whether known or unknown, and further covenants and
agrees that he shall not institute any suit,
proceeding or action at law, equity, arbitration,or
otherwise against American
Express, or in any way aid in the institution or prosecution of
any claim, demand, or cause of action against American
Express arising directly or indirectly
out of or in connection with Account No. REDACTED
7. Except for the terms and conditionscontained herein American
Express
acknowledgesand represents that it possesses no claims, demands, or causes of action
whatsoever against Defendant(s)
pertaining to Account No. REDACTED which are
not being resolved
pursuant to this agreement. Plaintifffs)forever waives and
relinquishes
any and all such claims, whether known or unknown, and further covenants and
agrees that it
shall not institute any suit,
proceeding or action at law, equity, arbitration,or otherwise
against Defendant(s), or in any way aid in the institution or
prosecution of any claim,
demand, or cause of action against Defendant (s) arising directly or indirectly out of or in
connection with Account No. REDACTED
This stipulation is in settlement ofthis action and only against the Defendant(s)
signing this stipulation.
Plaintiff(s)and Defendant(s) have read and agree to the terms set forth above.
DATED: June 9, 2021
Plaintiff: American Express Defendant(s):
/
V/'/,A
, LC-
/s/ Joshua Knurr
O Lisa DiSalle, Esq. bANTSGADO a/k/a
O Joshua James Knurr, Esq. DANIEL J SALGADO
Staff Attorneys for the Plaintiff 4813 Sw 21 St Street
American Fort Lauderdale, FL 33317
Express National Bank
American Express Legal
1-844-641-4041
PLEASE SEND ALL CORRESPONDENCE TO
AMERICAN EXPRESS LEGAL
P.O. BOX 278
RAMSEY, NEW JERSEY 07446
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Filing # 129911438 E-Filed 07/01/2021 01:22:43 PM Lisa DiSalle, Esq. FL Bar No.: 186236 Joshua James Knurr FLBar No..:1016695 American Express Legal 9550 Regency Square Blvd., Suite 501 Jacksonville, FL 32225 844-641-4041 Primary Email: Secondary Service Email: Staff Attorney for Plaintiff AMERICAN EXPRESS NATIONAL BANK, IN THE CIRCUIT COURT 17TH JUDICIAL CIRCUIT, IN AND FOR Plaintiff, BROWARD COUNTY, FLORIDA -against- CASE NO. : CACE-21-007763 DANIEL SALGADO Division : a/k/a DANIEL J SALGADO Defendant(s) STIPULATIONOF SETTLEMENT AMERICAN EXPRESS NATIONAL BANK ("Plaintiff) a national bank organized under the laws of the United States, ("American Express" hereinafter), with its headquarterslocated at 115 W. Towne Ridge Parkway, Sandy UT 84070. IT IS HEREBY STIPULATED AND and between the AGREED, by Attorney(s) for Plaintiff(s) and Defendant(s)and/or the Attorney(s) for the Defendant(s) that this matter has been discussed and a settlementhas been agreed to upon the following terms: *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 07/01/2021 01:22:43 PM.**** 1. Detendant(s) acknowledges service and receipt of the Summons and Complaint. Defendant(s) hereby withdrawsany answer, counterclaim or third-partycomplaint and waives any and all offsets,defenses, and claims against Plaintiff(s) and its/their attorney(s). 2. Defendant(s) agrees to pay Plaintiffthe settlement sum of $97,316.30 on account number REDACTED An initial payment of $4,055.00 was made by June 7, 2021, Thereafter, Defendant(s)agrees to pay Plaintiff(s)consecutive monthly payments of $4,055.00 due on or before the 78 of each and everymonthcommencing July, 2021 through and including April, 2023. Then, one final payment of $4,051.30 is due on or before the May 7,2023. 3. Upon full payment of all payments required under this agreement, Plaintiff(s) shall send, appropriate, as a stipulation of dismissal with prejudice or warrant to satisfy judgment to the Defendant(s) and to the Court within 30 days. However, if Defendant(s) fails to make any payment required under this agreement, Plaintiff(s) also referred to as American Express shall provide Daniel Salgado a/Ida Daniel J Salgado with written notice ofthe default and an opportunity to cure via regular mail and certifiedmail, return receiptrequested. If the event of Default is not cured within ten (10) days from the date ofmailing said notice certified mail, return receipt requested, then upon certification of counsel and without notice to the Defendant(s),Plaintiff(s)will be entitled to Judgment in the amount of $97,316.30 as per the Complaint, less any payments made or referenced hereunder, plus costs. Further, Daniel Salgado a/Ida Daniel J Salgado will only be entitled to a maximum of one (1) notice of default and opportunity to cure during the lifetime of this Agreement. 4. AH payments are to be sent to American Express P.O. Box 278, Ramsey, New Jersey 07446, by check payable to American Express referencing Account Number REDACTED REDACTED (the "Accounf). 5. This agreement resolves all claims each signatory party hereto may have against the other with respect to the Account which is the basis ofthis action. 6. Except for the terms and conditionscontained herein Defendant(s) acknowledgesand represents that he possesses no claims, demands, defenses, counterclaims, or causes of action whatsoever against American Express, its officers, directors, employees, agents, attorneys, heirs and assigns, pertaining to Account No. REDACTED which are not being resolved pursuantto this Agreement. Defendant(s) forever waives and relinquishes any and all such claims, whether known or unknown, and further covenants and agrees that he shall not institute any suit, proceeding or action at law, equity, arbitration,or otherwise against American Express, or in any way aid in the institution or prosecution of any claim, demand, or cause of action against American Express arising directly or indirectly out of or in connection with Account No. REDACTED 7. Except for the terms and conditionscontained herein American Express acknowledgesand represents that it possesses no claims, demands, or causes of action whatsoever against Defendant(s) pertaining to Account No. REDACTED which are not being resolved pursuant to this agreement. Plaintifffs)forever waives and relinquishes any and all such claims, whether known or unknown, and further covenants and agrees that it shall not institute any suit, proceeding or action at law, equity, arbitration,or otherwise against Defendant(s), or in any way aid in the institution or prosecution of any claim, demand, or cause of action against Defendant (s) arising directly or indirectly out of or in connection with Account No. REDACTED This stipulation is in settlement ofthis action and only against the Defendant(s) signing this stipulation. Plaintiff(s)and Defendant(s) have read and agree to the terms set forth above. DATED: June 9, 2021 Plaintiff: American Express Defendant(s): / V/'/,A , LC- /s/ Joshua Knurr O Lisa DiSalle, Esq. bANTSGADO a/k/a O Joshua James Knurr, Esq. DANIEL J SALGADO Staff Attorneys for the Plaintiff 4813 Sw 21 St Street American Fort Lauderdale, FL 33317 Express National Bank American Express Legal 1-844-641-4041 PLEASE SEND ALL CORRESPONDENCE TO AMERICAN EXPRESS LEGAL P.O. BOX 278 RAMSEY, NEW JERSEY 07446